The Iowa Court of Appeals decided Bell v. 3E and Travelers Indemnity. Bell was working as a sales employee for 3E when he slipped and fell in the lobby of his employer. As a result of the fall, he sustained a left shoulder, low back, and left wrist strain. Bell was ultimately released to work without restrictions and without limitations. Bell claimed that he had not reached maximum medical improvement and therefore his industrial disability should not have been assessed. Once an injured employee reaches maximum medical improvement, there is an assessment as to how that injured employee’s ability to work and earn a living is affected by the work-related injury. This is limited to hip, neck, back, and other body as a whole injuries. Bell was upset with the decision and felt that the judge failed to consider all of the evidence.

The Iowa Court of Appeals affirmed the opinion of the Iowa Workers' Compensation Commissioner.